Guide · Germany

The dual system: what it is and how to choose one

Registering in LUCID is free. The part that costs money is the dual system. Here is what it is, why you need it, and how to choose.

Facts checked: 28 October 2026

Based outside Germany? Representative first, then LUCID

Since 12 August 2026, companies without an establishment in Germany that sell directly to end users there must appoint an authorised representative in Germany before their first sale. The LUCID registration form asks you to select them: without a representative, you can't complete the registration.

Not law yet. On 20 October 2026 the European Parliament voted 616 to 9 to postpone this obligation until 2035 for small businesses established in the EU (fewer than 50 staff, under €10 million turnover). The Council also supports an exemption. Until it is adopted and published in the Official Journal, the obligation applies.

Council press release, 21 October 2026

Official ZSVR page We help you with this step: ask us

What a dual system does

In Germany, households throw packaging into yellow bags or bins, paper bins and glass containers. Licensed private companies, the system operators or “dual systems”, organise the collection, sorting and recycling across the country. As a producer, you pay a system to cover the packaging you put on the market. That's called system participation.

Do I need one?

Shipping packaging: always. According to the ZSVR, packaging used to ship goods to end users is always subject to system participation, even when the customer is a business.
Product packaging that ends up with households (or comparable places like offices or hotels): yes.
Packaging that never reaches end users (for example pallets in your own supply chain): usually not, but other duties apply. We check this per case.

Who are the system operators?

The ZSVR publishes the current list of licensed system operators, with contact details. All of them are legally equivalent: any licensed system fulfils your duty. The ZSVR itself isn't allowed to recommend one or share prices.

What drives the price

Weight per material: paper and cardboard, plastics, metals, glass and so on. You pay per kilogram.
Minimum fees and contract terms, which matter a lot for small sellers.
How you report: online tools, reporting intervals and correction fees.

How to compare

Weigh your typical parcel (box, filler, tape, label) and multiply by your yearly orders to Germany.
Split the weight by material.
Ask two or three systems for a price with those numbers, including any minimum fee.
Check the contract term, notice period and reporting intervals.
Sign before your first sale, then report the same quantities in LUCID.

Based abroad? Since 12 August 2026 your authorised representative signs the system participation agreement for you.

Questions

Is the dual system the same as LUCID?

No. LUCID is the public register (run by the ZSVR); the dual system is a private company you pay to recycle your packaging. You need both, and the data in both must match.

Can I switch dual systems?

Yes, within your contract's notice period. Report the change in LUCID as well.

What if I shipped more than I licensed?

Report the higher quantity to your system first, then file the same correction in LUCID.

Sources

Not sure where you stand?

Tell us what you sell and where you ship. We'll tell you what applies, even when the answer is "nothing".

Ask us to check